Course Delivery & Education Services

The data processed for these purposes will include a wide range of information we collect from you and from third parties, and which is generated through your contact with us. This will include contact information, education history and employment information, and details of your course, your study and learning activities, your progression and your academic performance. This includes:

• Information about your engagement with your course. This will usually include information about your attendance at classes (lectures, tutorials, supervisory meetings, lab sessions or other teaching sessions), your use of learning resources (including your use of the Brightspace VLE and library resources), your submission of work and your contact with BU academic staff, including your Personal Tutor and any research supervisor. In Health & Social attendance is also capture at Occupational Health appointments as an engagement point
• Information about your actual and expected academic progression and performance/attainment
• Your submitted assignments and assessment or examination papers
• Evaluations, reviews or assessments of and comments on your work, including marks and grades awarded
• Arrangements for assessments and examinations
• Details of assessments and examinations taken, your predicted and actual grades and other information in your student record; and
• Any communications between you and BU academic or administrative staff, and internal communications between BU staff which relate to you individually.

We process this information in our Faculties and in our administration teams to deliver your course/programme. We use it to deliver teaching, supervision and other academic support for your studies, to mark or assess your work and to provide you with access to all other relevant elements of our core teaching, learning and research services in accordance with the BU Student Agreement, including the facilities which form part of the core BU student experience. Our processing will include making arrangements for teaching, assignments, supervision meetings, examinations and other elements of your course content or requirements, and communicating with you about them. We use plagiarism detection software (Turnitin®) to review submitted assignments, and this involves putting your written work into a database maintained by Turnitin®in the United States. We also refer some submitted work to external examiners, i.e. academics working outside BU.

The University uses a learning analytics (LA) system. This helps staff to support students and to better understand student engagement and the learning experience. It is also intended to help students understand their own engagement with their learning. The LA system collects and combines different types of data regarding your engagement, attendance and learning to provide information about how you individually are engaging with your studies (in data dashboards) and to provide information about student engagement across a unit. The learning analytics system collects and analyses data held in other BU systems including SITS (the student record system) and Brightspace (the virtual learning environment), along with data collected through the Checkin + tool which is used to capture attendance at BU learning sessions. We capture data about your attendance and engagement because these are identified as important factors in students continuing with their studies and achieving good academic progress. In addition, BU is required to monitor the engagement and attendance of certain categories of student: this includes students with a student visa (as engagement is a condition of the student visa), students on apprenticeship courses and students on some courses accredited by regulatory bodies. Information is shared between the LA platform and other systems and teams within BU to support various reporting requirements, such as attendance & engagement. Your Personal Tutor and staff teaching you may refer to data in the LA data dashboards when discussing your academic progress with you. On the basis of data about your attendance and engagement we may contact you to check on your welfare, offer you support or notify concerns about compliance with attendance and engagement requirements (where relevant to you). Further information on LA and how attendance capture is used at BU, including a specific LA privacy notice and code of practice can be found here.

We may deliver some teaching, supervision, and assessment activities by remote or on-line methods, using facilities within BU systems or tools such as Zoom or Microsoft Teams. Where this is the case, the same types of data are processed as described above and for the same purposes. However, there may be additional recording of the data being processed, for example through use of recording, monitoring or messaging functions within the systems being used. BU staff will be transparent about the way in which they use these tools. To avoid any adverse impact on staff and other students, you will need to comply with any instructions or guidance given to you about how to engage with remote delivery and specific tools being used for it.

This processing is necessary to enable you to follow your programme of study in accordance with the BU Student Agreement (including relevant BU policies and procedures) and develop and progress academically, with a view to obtaining the academic standard required to achieve the qualification or credits associated with your course.

We process your data through the marking of your assignments and examinations, and in discussions and decisions about the award of marks, grades and degrees. For certain assignments and examinations your submitted work may be shared with external examiners, i.e. academics not employed by BU who provide an external perspective on the BU marking process to ensure that it is fair and maintains appropriate academic standards. For Postgraduate research, the thesis will be shared with external examiner(s) for the purpose of the viva voce examination. 

When you submit assignments for formal assessment through the Brightspace VLE, these will automatically be subject to a plagiarism detection review using Turnitin® software. This software uses textual similarity analysis to provide a plagiarism risk-rating for your work. This is shared with the BU staff member marking your work, who will consider whether any action is required. Your assignment will automatically be stored within Turnitin®’s database for reference in detecting plagiarism. Use of Turnitin® involves transfer of your personal data outside the EU, to the United States, but contractual arrangements and other protections are in place to ensure that your data receives the same protection as it would when held in the UK/EU.

We monitor your overall engagement with your course as part of the process of supervising and supporting your academic progress and supporting your wider interests and welfare. This is also relevant to compliance with immigration law requirements(e.g. Immigration Act 2016) and Student Sponsor Guidance. We will capture and share information about your attendance at specific teaching sessions where this is required either for professional regulatory body requirements (courses within the Faculty of Health & Social Sciences which lead to professional registration) or to satisfy the conditions of apprenticeship programmes. Attendance information may also be captured and shared in relation to other students: where this takes place, you should be informed by your Faculty or relevant academic staff about the data which will be captured and the reasons for this.

• Necessary for the performance of the contract between you and BU

• Necessary for performance of BU’s core public task, i.e. delivery of higher education and research

• Necessary for compliance with a legal obligation on BU: in compliance with Immigration Act 2016 [Art 6.1(c)]

We sometimes ask for your feedback on your academic experiences. We use your feedback on our courses and your study experience at BU to comply with our policies on programme monitoring and evaluation, in order to maintain and improve the quality of our courses and teaching activities and take decisions as to the nature and content of the programmes we will provide to students in the future. Further information on this is provided below.

We also process your data, including data about your academic progress and performance, to meet the requirements of our regulator, the Office for Students (OfS). We use this data to plan and execute activity to monitor and enhance the quality of our provision and support our Access and Participation Plan as required by OfS. More information about our reporting to OfS is provided in the Organisational Development section below.

• Necessary for the performance of the contract between you and BU

• Necessary for performance of BU’s core public task, i.e. delivery of higher education and research

• Necessary for compliance with a legal obligation on BU: we will identify the relevant obligation [Art 6.1(c)]

• Necessary for the purposes of substantial public interest

Academic appeals, student complaints, student disciplinary proceedings. Fitness to Practise and Support to Study proceedings.

We will share your data as necessary to manage these situations fairly in accordance with BU’s policies on appeals, complaints and disciplinary action. If you make an academic appeal or a complaint, this will usually mean disclosing information about the case to the individual(s) responsible for the matters you are complaining about. Information may be disclosed to individuals from outside BU who sit on panels who take decisions about this type of case.

We can share data externally with the Office of the Independent Adjudicator for Higher Education (OIA) if a complaint or appeal is referred to them. 

This will include processing of information about any health issues or other personal circumstances which you provide to us for consideration within these processes.

If you issue an academic appeal or make a complaint under our Student Complaints policy relating to any aspect of your course, or if there is a concern that you may have committed an academic offence or behaved in a way that justifies disciplinary action by BU or affects your suitability for a course leading to a regulated profession, we will process your data as necessary to apply the relevant BU’s policy and procedure and the BU Student Agreement. Our policies and procedures are intended to provide processes which are fair to all of those involved. Where relevant, we will process information about the work you have undertaken on the course and your academic performance and progression, including information about marks awarded to your work or examination scripts. We will share your information with senior staff within BU’s Students Union (SUBU) and/or with relevant NHS or other health and social care professionals from outside BU, where they are involved in determining complaints or appeals as provided for in our processes.

Following any Fitness to Practise proceedings we may need to report the outcome to external regulatory bodies (professional regulators such as the Nursing & Midwifery Council, or the Disclosure & Barring Service), if evidence collected or the outcome of the proceedings indicates that you may pose a risk to children or vulnerable adults or are otherwise not suitable to practise the relevant profession.

• Necessary for the performance of the contract between you and BU

• Necessary for performance of BU’s core public task, i.e. delivery of higher education and research

If, following completion of BU’s processes, you decide that you wish to refer a matter to the Office of the Independent Adjudicator for Higher Education (OIA) for determination of whether BU has complied with its policies, we are required to provide the OIA with full copies of the material considered under our processes and this will include sharing your personal data.

• Necessary for legitimate interests pursued by BU, i.e. to comply with agreements with external regulatory bodies

• Necessary for compliance with a legal obligation on BU: in compliance with OIA regulatory rules derived from s.11 Higher Education Act 2004 [Art 6.1(c)]

If you provide us with information about your personal circumstances, including health or disability information, on the basis that this is relevant to any appeal, complaint or allegation, then with your agreement we will process this information as necessary to complete the relevant BU process and share it with the OIA if you refer the matter to them.

• Consent: you have agreed to this processing

We process information about requests from students for consideration of exceptional circumstances which may be affecting their academic performance, in particular their ability to meet deadlines for submission of assignments or other course requirements.

Where the reasons given for the request relate to health conditions or disability, we will be processing special category data.

We will only process this as necessary for determining your request and implementing any special arrangements which are agreed.

• Necessary for the performance of the contract between you and BU

• Necessary for performance of BU’s core public task, i.e. delivery of higher education and research

• Consent: you have agreed to this processing

BU uses the Brightspace Virtual Learning Environment (VLE) to carry out many activities in respect of the management and delivery of its courses. This includes provision of access to learning and teaching resources, provision of personal and professional development resources for postgraduate researchers, use of Brightspace’s tools for communications between students and BU staff for management of courses and provision of teaching and learning support, submission of assignments (including referral of assignments to Turnitin®), capturing data relating to student attendance and engagement and transmission of marks and feedback on student work. Students will receive messages through Brightspace from BU staff regarding their study at BU. 

The Brightspace system is provided to BU by an external supplier and cloud-hosted. Our arrangements with the system and hosting suppliers include provisions as to data security.

Students access Brightspace through individual accounts. Students are not able to view material relating to or generated by other students, except where communications take place within a message board or other forum which is open to multiple students. Staff access material submitted through Brightspace as necessary for the purposes of their current teaching and administration responsibilities within their role at BU.

Brightspace includes functionality for capturing student attendance data which may be used where attendance is being recorded as described above. Brightspace also logs data about individual use of the system, e.g. when you log into the system and whether you have accessed certain materials hosted within it: this may be used to assess your engagement with your course and provide confirmation of your compliance with course requirements e.g. submission of assignments.

• Necessary for the performance of the contract between you and BU

• Necessary for performance of BU’s core public task, i.e. delivery of higher education and research

The library operates a number of systems which process your personal data, for the purposes of managing the University’s learning resources and ensuring you can access resources relevant to your study at BU. These systems will record information about the learning and research resources which you access and will also be used to send you messages relating to those resources or your study at BU.

Library enquiries, support requests and management of lost property left in the libraries are processed through the Library & Learning Support service, which can be accessed either through face to face contact with staff on campus or online. The data you give to the Library & Learning Support team will be used only to respond to your enquiry or request. We may access parts of your student record on the library services system or SITS (student record) system to enable us to respond effectively to your enquiries and requests and to return lost property to you.

From time to time the Library & Learning Support team may need to contact you about services such as the loan, renewal, return, reservation and use of library resources. In order to contact you we will access parts of your student record on the library services system or SITS system.

The library systems include:

• A Library Management System, supplied and hosted by an external provider, but utilising BU’s IT security arrangements. This will record information about the library resources that you borrow and will send you messages to advise you when those resources are due for return and overdue;
• A reading list system, supplied and hosted by an external provider, but utilising BU’s IT security arrangements. This provides guidance on learning resources relevant to your study at BU. This will record your name and e-mail address should you choose to create a personal profile.
• Booking and calendar systems, LibCal, used to management appointments and workshops. We retain information about the reason for any 1-2-1 appointments and use this to monitor and report on academic skills activities.
• A variety of online library resources (including LinkedIn Learning), supplied and hosted by external providers, but utilising BU’s IT security arrangements. Your university login enables you access learning resources relevant to your study at BU.

• Necessary for the performance of the contract between you and BU

• Necessary for performance of BU’s core public task, i.e. delivery of higher education and research

If you are studying at BU as part of an apprenticeship programme, we will share information about you, your attendance, your punctuality, your engagement and your academic progression and performance with the Education & Skills Funding Agency (ESFA), Ofsted, your employer (including the contract manager) and any other education provider involved in delivering your apprenticeship. This is done to comply with ESFA requirements to account for apprenticeship funding and conditions set by your employer, and to enable Ofsted to fulfil its duty to inspect apprenticeship provision. You will have been given details of this information sharing when you signed up for your apprenticeship.

We will record information about your attendance and punctuality at teaching and supervision sessions, so that we can provide this to your employer (or the main provider of the apprenticeship where BU is a sub-contractor for the apprenticeship). 

If BU is the lead provider of your apprenticeship programme, you will have signed a Training Plan which is an agreement between BU, your employer and yourself regarding the terms of your apprenticeship, and BU will provide information (about you, your attendance, your punctuality, your engagement and your academic progression) direct to the ESFA in accordance with their requirements for providing apprenticeship funding and to your employer in line with this agreement. Where an apprenticeship End Point Assessment is not conducted by BU, we are required to provide personal and contact details to the selected external End Point Assessment organisation.

If BU is delivering education courses to you as part of an apprenticeship programme provided by another education provider (e.g. Bournemouth & Poole College), we will provide information to the other provider so that they can then share information about you with your employer and the ESFA.

Ofsted has responsibility for inspecting and reporting on the quality of apprenticeship provision. We process data about the attendance and progression of apprentices as required by Ofsted as part of their inspection processes.

• Necessary for the performance of a contract between you and BU/others: this refers to your agreement to undertake the apprenticeship programme

• Necessary for the performance of a task carried out in the public interest: BU’s core purpose as a statutory higher education corporation (including provision of apprenticeships)

• Necessary for legitimate interests: employers’ interests in ensuring that employees undertaking apprenticeship programmes comply with the attendance requirements and other conditions of their absence from the workplace to undertake their course.

• Necessary for compliance with a legal obligation on BU: regulatory requirements of the Department for Education Apprenticeship rules and OfS ongoing conditions for providing education [Art 6.1(c)]

We will process information about your personal and family circumstances, academic and extra-curricular interests and academic performance and progression where this is relevant to the assessment of your suitability to receive a bursary/studentship or scholarship or your eligibility for BU Financial Support Funding (previously known as hardship funding). Where a bursary or scholarship is funded wholly or partly by a third party, at their request we will disclose basic information about your identity as the recipient of an award.

Depending on the terms & conditions, if you accept a bursary/studentship or scholarship then information about your academic engagement, performance or attainment may be shared within BU (for BU funded awards) or with any third party funding a bursary, scholarship/studentship or support. If you are a healthcare student, this would include the NHs Business Services authority where the Learning Support fund is concerns. In all cases you will be told about such terms & conditions when the bursary/studentship or scholarship is awarded.

In relation to BU Financial Support funding we may need to process information about your financial position, e.g. bank statements, in order to determine your eligibility for funding.

Where you provide any information relating to health conditions or disability in support of an application for BU Financial Support funding or other financial support, with your agreement we will be process this for the purposes of considering your application and administering payments.

• Necessary for legitimate interests pursued by BU, i.e. enabling access by students to additional financial support.

• Necessary for the purposes of a contract between us or to take steps preparatory to entering into a contract with you (e.g. a grant agreement to provide BU Financial Support funding)

• Consent: you have agreed to this processing

Where your course involves undertaking a work placement, a project which is delivered to a third party customer or a student exchange (i.e. where you undertake a period of study at a separate education provider) it will be necessary for your data to be shared between BU and the other organisation. We are likely to share your name, contact details, information about your course and details of your education and employment history in order to arrange the placement, project or exchange. Information will be shared between BU and the third party about your attendance and activities within the placement, project or exchange, including performance and progression information. Further information regarding NHS placements and Occupational Health can be found wthin this Privacy Notice.

• Necessary for the performance of the contract between you and BU

• Necessary for performance of BU’s core public task, i.e. delivery of higher education and research

• Necessary for legitimate interests pursued by BU, i.e. enabling access by students to opportunities relevant to academic study and/or future career opportunities.

Certain external research funding bodies impose requirements on BU to inform them if individuals working on a project funded by them are subject to investigation or sanction for bullying or harassment. These requirements are part of the terms and conditions of funding. The exact nature of the information which has to be disclosed and the timing of disclosures varies by individual funding body. You will be given more information about these potential disclosures if you are included in the team for a relevant research project. The funding bodies which impose this type of requirement currently include the Wellcome Trust, the British Heart Foundation and Cancer Research UK.

This section applies where you are following a course within the Faculty of Health & Social Sciences which is intended, if successfully completed, to enable you to meet the requirements for registration with a professional body. This includes certain nursing, midwifery, social work and paramedic science courses.

Prior to you commencing your course, if there are matters on your criminal record which are or would be shown on an Enhanced Disclosure & Barring Service check we will carry out an assessment of your suitability to undertake the course (which includes compulsory work placements in a regulated environment). Your data may be processed for the same purposes if you become subject to our Fitness to Practise procedure during your course.

We will share your data with the relevant professional body as necessary in relation to the confirmation of qualifications, compliance with professional registration requirements (including conduct requirements) and the accreditation of courses. This may include sharing information about your conduct, performance or progression while undertaking our courses, including any required work placements, and sharing information about any case relating to you within BU’s Fitness to Practise procedure. If you remain employed by a health or social care organisation while undertaking your BU course we may also share this type of your information with your employer if this is necessary for the purposes of public protection or effective professional regulation.

More information about processing of criminal records information for the purposes of risk assessment and suitability assessment is provided in the next section of this Privacy Notice.

• Necessary for the performance of the contract between you and BU

• Necessary for the performance of a task carried out in the public interest, i.e. professional regulation, maintenance of professional standards and protection of the public

• Necessary to protect the vital interests of another person

Processing of criminal records information is carried out under Article 10 UK GDPR, on the basis that paragraphs 6, 11 and 18 of Schedule 1 to the Data Protection Act 2018 apply [see further explanation later in this Notice].